FCA sets out steps to identify Key Workers in financial services

Today, the FCA has published a note on Key Workers in financial services. 

According to the FCA, all regulated firms will now be required to identify their Key Workers, who are staff members working to provide essential financial services. 

The types of roles that may be considered as providing essential services include:

• Individuals essential in the overall management of the firm, for example individuals captured by the Senior Managers Regime.
• Individuals essential in the running of online services and processing.
• Individuals essential in the running of branches and providing essential customer services, such as those dealing with consumer queries (including via call centres), client money and client assets and those maintaining access to cash and other payment services.
• Individuals essential to the functioning of payments processing and of cash distribution services.
• Individuals essential in facilitating corporate and retail lending and administrating the repayment of debt.
• Individuals essential in the processing of claims and renewal of insurance.
• Individuals essential in the operation of trading venues and other critical elements of market infrastructure.
• Risk management, compliance, audit and other functions necessary to ensure the firm meets its customers’ needs and its obligations under the regulatory system.
• Any individual that provides essential support to allow the functioning of the above roles, such as finance and IT staff.

To assist firms in identifying their Key Workers, the FCA has advised firms to look for individuals who support activities, services or operations which, if interrupted, are likely to lead to the disruption of essential services to the economy or financial stability. Firms should also identify critical outsource partners, who are essential to the continued provision of services, whether they belong in the financial services industry or not. 

In response to FCA’s latest guidance, our team is working on adding a new Key Worker section to the SM&CR tool of the EnOC Pro Platform, where members can easily log their Key Workers. We will make this available within the next few weeks, if not sooner - stay tuned for updates! ‍

UPDATE @ 25 March 2020: Customers of the EnOC Pro Platform are now able to use the Platform to identify their Key Workers and to also indicate the criteria by which they have been identified as Key Workers. And from there, the Platform will automatically generate a Register of Key Workers, keeping it simple for customers and for evidencing to the FCA.

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